There are written check lists and memory check lists and there are vastly different circumstances and different types of flying machines that can make it quite difficult to read a written check list before take off for instance.
I will exempt helicopters that are being operated on say a river with a strong current and use a Grumman Goose single pilot as our example.
You are maneuvering on a river with a strong current and a x/wind of say ten knots and are performing a take off check, how do you hold the list up where you can look out the window and still control the airplane?
This can be a very common situation in when flying that type of airplane.